CBP Provides Glimpse of IEEPA Refund Programming AND USTR Initiates New Section 301 Investigation

CBP’s IEEPA Refund Claim Process

As ordered by Judge Eaton of the CIT, CBP provided an update today on the status of their solution for importers to obtain IEEPA refunds. They are developing a new functionality in ACE called the Consolidated Administration and Processing of Entries (CASE). CASE will have four features:

1.) Claim Portal
The Claim Portal will be accessed through a tab in the ACE portal. Within the portal, importers or their brokers can file refund claims by uploading a CSV file that contains the entry summary information for entries subject to refund. CBP has stated that the Claim Portal is 70% complete.

2.) Mass Processing
CBP is working on the automatic removal of the IEEPA HTS classifications from the entries that have refund submission requests received through the claim portal. This Mass Processing feature is 40% complete.

3.) Review and Liquidation/Reliquidation
CBP is working on a process to review and liquidate unliquidated entries as well as reliquidate already previously liquidated entries that have received the refund claim. This feature is 80% complete

4.) Refund
After entries have liquidated/reliquidated with the removed IEEPA tariffs, CAPE will use a process within the ACE Collections refunds module to initiate refunds to the bank account listed in the ACE portal or the Notify Agent designated to receive the refunds on the importer’s behalf. This feature is 60% complete.

CBP believes they will have their solution ready by April 20, 2026. They believe at that time, CAPE should be able to process refunds for most entries. There are certain entries (example: those subject to AD/CVD duties, entries in a suspended status in ACE, warehouse withdrawals, entries with a drawback claim) that may require additional time for CBP to formulate a refund solution.

Importers are STRONGLY urged to get their ACE Portal importer account set up. CBP will no longer issue refunds via check. They will only issue refunds electronically. Once importers have their ACE portal set up, they need to navigate to the ACH Refund Authorization tab (see pages 6-10) and input their banking information. Many importers are struggling with this process. It’s taking some importers weeks to resolve issues with the setup process. Importers need to get their ACE Portal account set up as soon as possible. Do not delay.

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USTR Issues New Section 301 Tariffs
The USTR initiated a slew of new Section 301 Investigations on Wednesday, March 11, 2026. This did not come as a surprise. When the Supreme Court struck down the IEEPA tariffs, it was expected that the Trump Administration would use the Section 301 to fill the void. The countries that are subject to the new Section 301 investigations are as follows:

China
EU
Singapore
Switzerland
Norway
Indonesia
Malaysia
Cambodia
Thailand
Korea
Vietnam
Taiwan
Bangladesh
Mexico
Japan
India

You can read more details in the Federal Register posting.

There will be a comment period opened up on March 17, 2026. Those who wish to file comments can add them on the public dockets website. The deadline for posting comments is April 15, 2026.

USTR will hold hearings on these new Section 301 investigations on May 5, 2026. The assumption is that the USTR is hoping to complete their investigation and have section 301 tariffs ready by the time the section 122 tariffs expire on July 24, 2026. While past section 301 investigations have taken much longer, the administration may be able to fast track the processing of these section 301 investigations. Importers should plan accordingly.